On behalf of the Independent Women’s Forum, I am submitting comments regarding the National Labor Relations Board (NLRB) Notice of Proposed Rulemaking entitled, “Standard for Determining Joint-Employer Standard,” which was published in the Federal Register on September 7. The proposal would impose an unclear, untested new standard for determining joint-employment status of employees on America’s business owners.

Independent Women’s Forum (IWF) is the leading national women’s organization dedicated to developing and advancing policies that are more than just well-intended, but enhance people’s freedom, opportunities, and well-being. As a 501c3 non-profit organization, IWF works every day to engage and inform women about how policy issues impact them and their loved ones. 

IWF celebrates women’s accomplishments and fights to expand women’s options and opportunities. We support policies that reduce government red tape and return resources and control to people, so that we have healthy communities and people can pursue their own visions of happiness.

The U.S. has 12.3 million women-owned businesses, representing 40% of all firms and generating generate $1.8 trillion a year for the economy. Every day 1,817 new women-owned businesses start up. As a result, there are 11.4% more women entrepreneurs today than there were 20 years ago. Sixty-two percent of women entrepreneurs cite their business as their primary source of income. Moreover, a growing number of women are part-time entrepreneurs — a category that increased by 39% between 2014 and 2019. For these “sidepreneurs,” a part-time business offers them the ability to pay bills and build wealth while pursuing a passion.

Franchising also has experienced a significant increase of women in its ranks. According to the International Franchising Association, 30.6% of franchisee businesses are owned by women.

IWF is very concerned that the NLRB’s joint employer rule will undo the great success women entrepreneurs have enjoyed over the last two decades by effectively shrinking the market and/or increasing the liability and compliance costs for the firms they run.

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